Asia Gaming Brief looks at existing and upcoming grey market licensing jurisdictions and compares what they offer to the industry. This week we take a look at Anjouan.
We shine a light on everyone from Curacao to Kahnawake and Tobique, presenting you with the basic facts and analyzing the pros and cons of every jurisdiction based on our in-depth expertise, industry feedback, and decades of experience in the field. We continue the series with one of the newer jurisdictions vying for business, Anjouan.
What & where is it?
Anjouan is an autonomous volcanic island in the southwestern Indian Ocean. Located off the east coast of Africa, between Mozambique and Madagascar, Anjouan is one of the three main islands that make up the country of Comoros. It has around 360,000 inhabitants, with most of them living in the capital city of Mutsamudu.
The current gaming legislation is called the Computer Gaming Licensing Act 007 of 2005. While the jurisdiction has therefore been around for a while, it has only really been marketed more heavily in the last year or two, and in the wake of the Curacao changes.
What licenses does it offer?
Anjouan calls its license a “comprehensive” one that covers B2C and B2B, as well as various verticals including casino, sports betting, poker, and lottery. White Labelling is also allowed, but sub-licensing is not. The jurisdiction requires local data replication which is part of the license fee. One Key Person (similar to the Designated Official in the Isle of Man) is also included. Additional Key Persons can be added at a cost, as can additional URLs as only two website addresses are included per license.
Applicants have to undergo a reasonably strict due diligence process as well as pass a compliance check and provide various policies to show adherence to regulations. While not as heavy as in other jurisdictions, licensing due diligence requirements appear adequately strict to ensure only suitable applicants are approved.
Cost & Taxes
License fees including initial setup fees and required ISP service for compliance backups is EUR 17,000 ($18,500). Additional Key Persons can be added at a cost of EUR2,000 ($2,150) each.
There is no gaming tax.
What countries can you target?
Anjouan currently states the following territories as being restricted or prohibited, and the regulator requires that they must be GEO IP blocked: Australia, Austria, Comoros, France, Germany, Netherlands, Spain, United Kingdom, USA, all FATF Blacklisted countries, and/or any other jurisdictions deemed prohibited by Anjouan Gaming Board and Offshore Financial Authority.
The guidance also states that licensees are required to have done their due diligence prior to accepting and registering players from any territory ensuring compliance with local laws. This essentially means operators should obtain a legal opinion if there is uncertainty about the legality of operations in any territory. This is in line with other jurisdictions.
How long does it take?
The stated processing time is currently two to three weeks, making an Anjouan online gambling license one of the quickest ones a company can obtain. Adding some time to prepare the required paperwork and it should be feasible to complete the process in as little as two to three months.
Do I need a company there?
No. The Anjouan regulator does not require the gaming company to be on the island. Businesses are therefore free to choose a company in other jurisdictions to apply for the license. There is an option to have an Anjouan International Business Corporation registered on the island as part of the licensing process and this is currently priced at around $4,000. A local data backup is required but this is part of the license fee.
Do I have to go there?
No. Anjouan licenses are administered on the island and there is no requirement to travel to the island.
Can I get banking and payment services?
Generally, yes. The general claim is that Anjouan is seen in a similar light as the Curacao of old, meaning companies should be able to engage with certain PSPs and some banks. However, in some cases, it might be necessary to engage with payment partners through a separate entity, depending on where the licensed company is based. This will also be a familiar procedure for anyone who has held a Curacao license in the past. You will be looking at the same kind of Cyprus, Isle of Man, or other payment setup that was required there.
Is the license accepted by suppliers and third parties?
Generally, yes. From what we are hearing and seeing, Anjouan licenses can be used to satisfy the compliance requirements of many software suppliers. As this greatly varies from company to company, it is always recommended to check before applying for an Anjouan license. Having seen how popular the license has become in recent times, and that little negative feedback in terms of acceptance has surfaced, it does indeed seem to be roughly on the same level as the Curacao from years gone by.
Pro and Contra Summary:
- Anjouan is selling itself as the New Curacao, meaning it wants to offer quick and convenient licenses at a reasonable cost. Although the current gaming legislation has been in place since 2005, the island can be seen as a relative newcomer to the grey market licensing game. Its rise in popularity came as a result of changes in other places like Curacao and it will remain to be seen how the jurisdiction will grow in the future.
- A quick turnaround time and the relatively low price tag will be very appealing to many companies looking to obtain a license and potentially make the island a suitable option for smaller operators and startups. The underlying legislation appears somewhat lightweight when compared to other jurisdictions, which may cause lower levels of comfort for compliance departments.
- In the long run, global compliance requirements are getting ever stricter and often it is not the gaming regulator making the real rules, but the banks and payment providers behind them. As it is possible to get payments with an Ajouan license at the moment, it certainly seems like an appealing and cost-effective option. Its long-term credibility and suitability in the market will remain to be seen, especially with other jurisdictions also getting in on the game.
